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Export turnover brought into India does not qualify as 75% of total turnover for claiming exemption u/s 10A. Expenditure incurred in foreign exchange must be excluded from both total turnover and export turnover to maintain parity. Section 10A, being a beneficial provision, should be interpreted liberally to promote exports. Excluding foreign exchange expenses from export turnover but not total turnover would defeat the purpose. The ITAT directed the Assessing Officer to compute 75% of total sales on gross receipts u/s 10A(2)(ia) and allowed the assessee's appeal.
Export turnover brought into India does not qualify as 75% of total turnover for claiming exemption u/s 10A. Expenditure incurred in foreign exchange must be excluded from both total turnover and export turnover to maintain parity. Section 10A, being a beneficial provision, should be interpreted liberally to promote exports. Excluding foreign exchange expenses from export turnover but not total turnover would defeat the purpose. The ITAT directed the Assessing Officer to compute 75% of total sales on gross receipts u/s 10A(2)(ia) and allowed the assessee's appeal.
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